At Cole Steadman, we are committed to protecting the privacy and security of our customers and site visitors, including you. The Cole Steadman Real Estate team members are also users themselves, both on http://www.steadman.xyz/ and other Internet sites. We therefore fully appreciate and respect the importance of data privacy and security on the Internet.
In general, our website automatically gathers certain usage information like the numbers and frequency of visitors to Cole Steadman. We only use such data in the aggregate. This aggregate data helps us determine how much our clients use parts of the website, so we can improve our website to assure that it is as appealing as we can make it for as many of you as possible.
We believe you should feel both informed and empowered when it comes to our handling and usage of your information. This notice therefore explains:
• what information we collect when you’re using Cole Steadman website or mobile app, or when you’re communicating with us;
• why we collect that information;
• how we may then use that information;
• how we share that information;
• how long we keep your information, and how we protect it whilst we have it;
• what we won’t do with your information; and
• what choice and options you have to control your information.
TYPES OF INFORMATION COLLECTED AND PROCESSES FOR COLLECTION
We collect information about you and your use of the Website, Applications, and Platform through various means, including when you provide information to us and when we automatically collect information about you when you access, use, or interact with the Platform. Such processing is necessary to provide you with the Platform.
If you don’t want us to collect or process your personal information in the ways described in this policy, you should not use the Platform. We are not responsible for the content or the privacy policies or practices of any of our members, third-party websites, or third-party apps.
By using the Website and Platform, you acknowledge that we will use your information in Utah, United States of America and any other country where we operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to these countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy appropriate protections. Please read on to learn more about how we protect personal information that’s transferred outside of Europe. The types of information the we may collect about you include:
CATEGORIES OF PERSONAL INFORMATION ACQUIRED ABOUT YOU
Depending on the Service that you use or select, we may collect, obtain or otherwise acquire the following types of Personal Information about you, and we make and retain inferences drawn from such information:
• Identifiers, such as your name, signature, postal address, zip code, email address, telephone number, unique online identifier, IP address, User ID, and Device ID.
• Certain characteristics, such as gender, marital status, nationality, and country of origin, that are protected by applicable law.
• Commercial information, such as purchase history.
• Internet or other electronic network activity information, such as website or app activity data, call logs, text messages, and emails.
• Geolocation data, such as the precise physical location of your Device.
• Audio, electronic, visual, thermal, olfactory, or similar information, such as voice recordings, video recordings, physical characteristics or description, and photos.
• Professional or employment-related information, such as occupation, employment history and record, and resume.
• Education information such as academic record.
• Location Details - physical address, billing address, time zone.
• Identity Details - full name, proof of identity (e.g. drivers license, passport), proof of address (e.g. utility bill), photograph of the user.
• Financial Information - credit card details, wire transfer details, payment processor details (e.g. Skrill, PayPal), tax numbers.
We may allow visitors to provide information to be published or displayed on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Submission”). Your User Submissions are posted on and transmitted at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users on the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
HOW WE ACQUIRE PERSONAL INFORMATION
Personal Information You Provide: We often receive Personal Information because you provide it to us. For instance, when schedule or book a call or an appointment with us, complete a survey, or register and/or set up an account/profile. You may be provided with, or required to choose, a password and/or User ID, and you may provide a credit, debit, or payment account number, or other payment information, as well as your name, telephone number(s), email and/or street address. Other Personal Information such as your age, gender, and preferences may also be requested. In addition, we may acquire your Personal Information when you contact us by telephone, postal mail, social media interaction or messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire Personal Information that you provide about other people, for example, when you use our “refer-a-friend” email feature or purchase one of our Products as a gift.
Information We Gather Through Automated Collection: As you visit and make use of the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
• Details of your visits to and uses of the Platform, including traffic data, location data, logs and other communication data and the resources that you access and use on the Platform (including your IP address, browsing and navigation patterns, click stream data, device metrics, etc.)
• Information about your computer, mobile device and internet connection, including your IP address, operating system and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Platform and to deliver a better and more personalized service, including by enabling us to: (1) estimate our audience size and usage patterns, (2) store information about your preferences, allowing us to customize the Platform according to your individual interests, (3) speed up your searches, (4) recognize you when you return to our Website, (5) optimize your user experience across the Platform.
The technologies we use for this automatic data collection may include:
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permits us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Unique Identifiers: When you use or access the Platform, we may access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Websites. Some features of the Platform may not function properly if use or availability of Unique Identifiers is impaired or disabled.
• Analytics Information: We use data analytics to ensure site functionality and improve the Platform. We use mobile analytics software to allow us to understand the functionality of the Platform on your phone. This software may record information such as how often you use the Platform, what happens within the Platform, aggregated usage, performance data, app errors and debugging information, and where the Platform were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
• Log File Information: When you use our Platform, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Platform, for example, when you visit our websites, sign into our Platform, or interact with our email notifications. We use log file data to provide, understand, and improve our Websites, and to customize the content we show you. We may link this log file to other information that we collect about you via the Platform.
• Public Information: We may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Notice, and may be accessed and collected by us. Please be aware that any content or information you share with or provide to third parties using or related to your use of the Platform is neither private, nor confidential. Cole Steadman is not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it.
Any information that we collect automatically may be paired with personal information about you that we collect from other sources or you provide to us. We process the information we collect about you automatically on the legal basis of our legitimate interests in providing the function or service you requested. We may rely on alternate legal bases where appropriate, such as your consent to certain types of processing.
HOW WE USE YOUR INFORMATION
We use the information we receive about you for the purposes described in this Privacy Notice. We process certain personal data received about you through our Platform on the legal basis of our legitimate interests in providing the Platform and its functionality to you. Such processing is necessary for the purposes of the legitimate interests pursued by us or by our Service Providers related to the Platform. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing, or where such processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
We use information that we collect about you or that you provide to us, including any personal information:
(1.) to present our Platform and its contents to you, including to optimize the use of our Platform and its interface,
(2.) to provide you with communications, information or services, including those that you request from us,
(3.) to analyze your use of the Platform in order to update, modify, improve, tailor, customize, or otherwise adjust the Platform and its features
(4.) to fulfill any other purpose for which you provide it,
(5.) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us,
(6.) to notify you about changes to our Platform or any services we offer or provide though it,
(7.) to allow you to participate in interactive features on our Platform,
(8.) in any other way we may describe when you provide the information,
(9.) or any other purpose with your consent.
The following table provides legal basis identifications for certain uses of your information.
Use of information Legal basis
(1) to present our Platform and its contents to you, including to optimize the use of our Platform and its interface GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(2) to provide you with communications, information or services, including those that you request from us GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(3) to analyze your use of the Platform in order to update, modify, improve, tailor, customize, or otherwise adjust the Platform and its features GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(4) to fulfill any other purpose for which you provide it GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(5) to provide you with notices about your Cole Steadman GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(6) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract.
(7) to notify you about changes to our Platform or any services we offer or provide though it GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(8) to allow you to participate in interactive features on our Platform GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(9) in any other way we may describe when you provide the information GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.
(10) or any other purpose with your consent GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Notice.
Where you have provided consent, you have the right to withdraw that consent at any time by email@example.com, but a withdrawal of consent will not affect its validity up until the point you have withdrawn it.
HOW YOUR INFORMATION MAY BE DISCLOSED AND SHARED
We may disclose aggregated information about any user of or visitor to the Platform, including information that does not identify any individual, without restriction. We will not share, sell, rent, or otherwise disclose your private personal information to third parties without your consent or another valid legal basis permitted by law.
We will share your information in the following circumstances on the legal basis of the legitimate interests of providing the requested Services:
• Subsidiaries, Affiliates, and Personnel: We may share the information within the Organization and to our subsidiaries and affiliates. Our personnel may have access to your information as needed to provide and operate the Platform in the normal course of business. This includes information regarding your use and interaction with the Platform.
• Partners: We may share the information with our employer partners who will interview and/or hire you upon or after the completion of our programme
• Service Providers: We work with various individuals, organizations, contractors, vendors (“Service Providers”), including for the performance of hosting, providing analytics, performing research, undergoing development on the Platform, and engaging in social media services, as well as to other third parties as we determine necessary to support our business, including to students, teachers, alumni, and mentors who may or may not be on the Platform. These third parties have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share with our Service Providers may include both information you provide to us and information we collect about you, including personal data and information from data collection tools like cookies, web beacons, and log files. We share personal information with our Service Providers on the legal basis of our legitimate interests in providing you with the Platform. Our engagement of Service Providers is often necessary for us to provide the Platform to you, particularly where such companies play important roles like helping us keep our Platform operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Platform, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Platform better.
• Business Transactions: We may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including personal data, may be among assets sold or transferred as part of a Business Transaction.
• Lawful Requests: We may be required to disclose Platform user information pursuant to lawful requests such as such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Platform or using our name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
HOW YOUR INFORMATION IS PROTECTED
Whenever Personal Information about you is stored on our computers, that information is password-protected from unauthorized access or use. In addition, this information is kept on servers that are located behind a firewall.
Since your financial information is especially sensitive, we take special care to keep it secure. Your credit card number and financial information are stored on secure, designated servers and access is limited to individuals in departments charged with using such information only in connection with processing your orders for products and services purchased.
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
YOUR RIGHTS ACCORDING TO GDPR LAW
Cole Steadman Real Estate Team seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to each individual data subject and may not apply to you depending upon your jurisdiction.
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us. Upon request, we will provide you with information about whether we hold any of your personal information. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format.
To the extent that such rights are mandated by the laws applicable to the individual data subject, such as all data subjects residing in the European Union (“EU”), the following rights may apply: the right to access (GDPR, Article 15); the right to rectification (GDPR, Article16); the right to erasure (GDPR, Article 17); the right to restrict processing (GDPR, Articles 18); the right of object (GDPR, Article 21); and if applicable, the right to data portability (GDPR, Article 20). You may also have a right to lodge a complaint with an appropriate data privacy regulatory authority (GDPR, Article 77).
If we process your information based on our legitimate interests as explained in this Privacy Notice, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings if you have registered or scheduled an appointment with Cole Steadman Real Estate Team. However, please note you may not opt-out of Platform-related communications, such as account verification, changes or updates to features of the Platform, or technical and security notices.
Where you have provided consent to certain data processing, you have the right to withdraw that consent at any time. A withdrawal of consent will not affect the validity of our use of your personal data up until the point you have withdrawn your consent.
You may request to:
• Receive confirmation as to whether or not personal information concerning you is being processed and access your stored personal information, together with supplementary information.
• Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
• Request rectification of your personal information that is in our control.
• Request erasure of your personal information.
• Object to the processing of personal information by us.
• Request to restrict processing of your personal information by us.
• Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you wish to exercise any of the above rights or receive more information, please contact our Data Protection Officer (“DPO”) using: firstname.lastname@example.org.
ACCESS TO THE INFORMATION WE HAVE COLLECTED ABOUT YOU
Cole Steadman implores you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Platform uses of your information, or to withdraw any consent you may have granted to us. You can change, correct, request the deletion or removal of, and express any concerns relating to the collection, use, or disclosure of your personal information by e-mailing email@example.com. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may retain the information we receive about you for as long as necessary to fulfil our contractual and legal obligations, consistent with our data retention schedules, or indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. In addition, we may delete your personal data from our systems as part of a data retention plan. Following termination or deactivation of Cole Steadman, the we may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
Please note requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Platform, may no longer be available to you.
You also have the right to ask to see what information we hold about you, and what we are doing with it. This is known as a Subject Access Request, and must be made in writing to firstname.lastname@example.org.
You also have a right to request your information in a format which supports its portability. Please contact email@example.com should you wish to exercise this right.
DO NOT TRACK
We do not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use the Platform. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
CHANGES TO OUR PRIVACY NOTICE
It is our practice to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and Platform and this Privacy Notice to check for any changes.
INTERNATIONAL TRANSFER OF INFORMATION
Please note information we collect about you may be transferred, processed and/or accessed by us in Utah, USA or another country where we, or our Service Providers operate. Please be aware your personal data may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. If you are located outside Utah, USA and choose to allow us to collect information about you, please be aware that we may transfer your personal data to the Australia and process and store it there.
If you are located in the European Economic Area (EEA) or other regions with laws governing data collection and use that may differ from American law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Notice. It may also be processed by staff operating outside the EEA who work for us or for one of Service Providers, also as disclosed.
We agree to the following:
• Users can visit our site anonymously.
COPYRIGHT AND TRADEMARK NOTICE
The contents of this site are the exclusive property of Cole Steadman and may not be copied, distributed, displayed, altered or modified, or reproduced or transmitted, in any form or by any means including, but not limited to, electronic, photocopy, or otherwise, without the prior written permission of Cole Steadman. The corporate and product names, slogans, logos and other content contained on this site are the registered or unregistered trademarks or service marks of Cole Steadman or are used by Cole Steadman with the permission of their owners. The use, copying or alteration of any Trademark without the express prior written consent of Cole Steadman or, where applicable, the registered owner's express prior written consent is strictly prohibited. The Trademarks are protected under the Trademark Act and by state or common law.
As discussed above, you can always choose not to provide information, although it may be required to engage in a certain activity on the Website. We will send you information regarding updates about our products and promotional offers. You cannot opt-out of Administrative Emails.
"Administrative Emails" relate to a User's activity on the Website, and include emails regarding a particular User's account and requests or inquiries. If you do not wish to receive them, you have the option to deactivate your account. In contrast to Administrative Emails, however, you do have a choice with respect to Promotional Emails. Promotional Emails advertise our products and services, and/or the products and services of our Advertisers and Affiliates. If you do not want to receive Promotional Emails from us, you may select to opt-out of receiving Promotional Emails at any time after registering by hitting the "unsubscribe" button at the bottom of any of our e-mails. When contacting us, please indicate your name, address, email address, and what Promotional Emails you do not want to receive.
CAN SPAM ACT
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to send information, respond to inquiries, and/or other requests or questions.
To be in accordance with CANSPAM we agree to the following:
• NOT use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. This Platform is not intended for children living who are under 16 years of age. No one under the age of 16 may provide any information to or on the Platform. Under no circumstances shall we allow the use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors.
If we determine that we have collected or received any information from any child under the age of 16, we will delete that information immediately. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us using the contaact details below or, contact us at firstname.lastname@example.org to provide additional information or to request the removal of the relevant information from our database.
If you feel that we are not abiding by this Privacy Notice, you should contact us immediately via email at email@example.com.
ACCEPTANCE OF POLICY
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
ACCURACY OF CONTENT
While Cole Steadman uses its best efforts for the information contained in this site to be as accurate and reliable as possible, errors may sometimes occur. Cole Steadman reserves the right to revise the information contained on this site and to make such changes without notice to past or present users of our site. Links to Other Sites To this extent that this site may now or in the future include links, facts, opinions or recommendations of different individuals or organizations, Cole Steadman does not guarantee the accuracy or completeness or otherwise endorse these links, facts, opinions and recommendations.
GENERAL DATA PROTECTION REGULATION (GDPR)
(a) “Data Protection Legislation” means European Directives 95/46/EC and 2002/58/EC, and any legislation and/or regulation implementing or made pursuant to them, or which amends or replaces any of them (including the General Data Protection Regulation, Regulation (EU) 2016/679);
(b) “Data Processor”, “Data Subject”, “Processor”, “Processing”, “Sub processor”, and “Supervisory Authority” shall be interpreted in accordance with applicable Data Protection Legislation;
(c) “Personal Data” as used in this Addendum means information relating to an identifiable or identified Data Subject who visits or engages in transactions through your website (a “Customer”), which Cole Steadman Processes as a Data Processor in the course of providing you with the Services. Notwithstanding the foregoing sentence, Personal Data does not include information that Cole Steadman processes in the context of services that it provides directly to a consumer, such as through its consumer-facing applications or its consumer-facing services; and
(d) All other capitalized terms in this Addendum shall have the same definition as in the Agreement.
1. Where a Data Subject is located in the European Economic Area, that Data Subject’s Personal Data will be processed by Cole Steadman, in Utah, United States based servers.
2. When Cole Steadman Processes Personal Data in the course of providing the Services, We will:
• Process the Personal Data as a Data Processor, only for the purpose of providing the Services in accordance with documented instructions from you (provided that such instructions are commensurate with the functionalities of the Services), and as may subsequently be agreed to by you. If Cole Steadman is required by law to Process the Personal Data for any other purpose, Cole Steadman will provide you with prior notice of this requirement, unless Cole Steadman is prohibited by law from providing such notice;
• notify you if, in Cole Steadman' opinion, your instruction for the processing of Personal Data infringes applicable Data Protection Legislation;
• notify you promptly, to the extent permitted by law, upon receiving an inquiry or complaint from a Data Subject or Supervisory Authority relating to Cole Steadman' Processing of the Personal Data;
• implement and maintain appropriate technical and organizational measures to protect the Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration or disclosure. These measures shall be appropriate to the harm which might result from any unauthorized or unlawful processing, accidental loss, destruction, damage or theft of Personal Data and appropriate to the nature of the Personal Data which is to be protected;
• provide you, upon request, with up-to-date attestations, reports or extracts thereof where available from a source charged with auditing Cole Steadman' data protection practices (e.g. external auditors, internal audit, data protection auditors), or suitable certifications, to enable you to assess compliance with the terms of this Addendum;
• notify you promptly upon becoming aware of and confirming any accidental, unauthorized, or unlawful processing of, disclosure of, or access to the Personal Data;
• ensure that its personnel who access the Personal Data are subject to confidentiality obligations that restrict their ability to disclose the Customer Personal Data; and
• upon termination of the Agreement, Cole Steadman will promptly initiate its purge process to delete or anonymize the Personal Data. If you request a copy of such Personal Data within 60 days of termination, Cole Steadman will provide you with a copy of such Personal Data.
3. In the course of providing the Services, you acknowledge and agree that Cole Steadman may use Subprocessors to Process the Personal Data. Cole Steadman' use of any specific Sub processor to process the Personal Data must be in compliance with Data Protection Legislation and must be governed by a contract between Cole Steadman and Sub processor.
GROUNDS FOR PROCESSING
When we collect from you any personal information within the scope of European data protection laws, we do so (a.) with your consent; (b.) where necessary to provide the Service, fulfil a transaction or otherwise perform a contract with you or at your request prior to entering into a contract; (c.) where necessary for our compliance with a legal obligation; (d) where necessary for the performance of a task carried out in the public interest; and/or (e.) as necessary to fulfil our legitimate interests as described below, except where our interests are overridden by your privacy rights. Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you have the right to object.
Our legitimate interests are: to deliver our information to our users; to detect or prevent fraud; to protect the security of our systems, customers and users; to further develop our products; to conduct direct marketing; to operate our business (by processing payments/invoices and conduct credit checks on customers, suppliers and leads, perform sales and customer relations management, supplier management, as well as incidental processing in our back office for these purposes); to enable our customers to comply with legal obligations; to provide customer service or support; or fulfil our other legitimate interests as described above.
We hope this policy responds to your questions about our collection, use and disclosure of your personal data. If you have additional questions or want to contact us for a specific purpose, please select from the following:
• Access/Corrections: Please send any request to access, amend or delete certain personal data we hold about you to the contact address below.
• Complaints and other questions: You should send any questions you may have about this policy or any complaints you have about how we have handled your personal data to the contact address below. If you feel our response is not satisfactory, we will refer you to a neutral and independent dispute resolution organization.
• Security: If you have reason to believe that the personal data we hold about you, or other membership information is no longer secure, you must immediately notify us of the problem by either visiting the Support Page on our website or writing to our Physical Address:
2901 W, Bluegrass Blvd Suite 200, Lehi, UT 84043 or Email: firstname.lastname@example.org
We appreciate your concerns and will seek to resolve any concerns and disputes. Thanks for reading. Hope we made you feel a little more comfortable about using our website.
Last Updated: September, 2020.
Wasatch Life Realty | Licensed As Steven Cole Steadman | 2901 W, Bluegrass Blvd Suite 200, Lehi, UT 84043 | (877) BUY-LEHI | License #: 10708413-SA00